| Comment Number: | OL-10501381 |
| Received: | 2/24/2005 9:02:15 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
Subpart C (Pay and Pay Administration): It is not clear that upon initial conversion that overtime will still be paid out at a rate equal to that currently covered under the current system. The NSPS rules should specifically indicate that during the intial conversion periods, current overtime rules still apply so that the aggregate amount allocated for compensation of DoD civilian employees under NSPS will not be less than if they had not been converted to the NSPS. Over a period of time, high performing workers under the NSPS system will receive raises to compensate for their value to the workforce - the current system simply encourages management to overwork high performance workers and compensate them with overtime pay, and discourages management from using low performing workers from work (a sort of inverse reward system). If the goal is to transition to a system without direct overtime compensation (true salary - contract compensation for expectations of work), then the time period from this initial conversion period to the full implementation of NSPS without overtime can only work if the rating periods and performance payouts correspond to actual salary raises (vice one-time bonuses) that will adequately compensate high performing workers fairly. These rules will support recruitment and retention efforts afforded in Subpart E (Staffing and Employment) of the proposed NSPS, especially for high performing workers who become more valuable and retention of these assets are critical (to retain high performing assets).